NS E-PASS is a social networking service provided by Jamaica North-South Highway Company Ltd (hereafter referred to as "we", “us”, “our”); registered address: Management Centre, Treadways District, P.O. 4638, Linstead, St. Catherine, Jamaica.

The Jamaica North-South Highway Company Ltd views privacy issues very seriously. These privacy issues, includes but is not limited to the security and confidentiality of personal data, including personal information that is disclosed on or through the NS E-Pass platform. The NS E-PASS Privacy Policy explains how the Jamaica North-South Highway Company Ltd collects, uses,shares, stores and protects your personal information when you use NS E-PASSThis policy complies with the Data Protection Act of Jamaica

During your use of NS E-PASS services, we will collect and use the personal information that you actively provide or that is generated as a result of using the services in the following ways:

1.1 When you register a NS E-PASS account, we will collect and use your alias, profile photo, and mobile number. The purpose of collecting this information is to complete the registration process, which will enable you to use NS E-PASS features such as social networking, and protect the security of your account. The collection and use of your mobile number is also necessary to comply with the requirements of applicable laws and regulations regarding the authentication of identity information. Your failure to provide such information may result in your inability to use our services as intended. Optionally, you may also provide your gender, region and other information, if you desire.

1.2 During your use of NS E-PASS services, we collect and use certain technical information in order to: (i)ensure that you can use our services normally(ii)maintain the normal operation of the services (ii) improve and optimize user experience and (iv)protect the security of your account.

We also collect and use your other information such as your device model, operating system, unique device identifier (such as AndroidID/OAID for Android devices, IDFA for iOS devices prior to iOS 14.5), login IP address, NS E-PASS version number, the method, type and status of network connection (SSID, BSSID, etc.), network condition data, device accelerators (such as gravity sensor), operation logs, service logs (such as your records of searches and views in NS E-PASS, service failures information, and referral URLs, etc.).

In addition, , to prevent viruses, Trojan programs, or other malicious software and websites, we may collect information about the applications installed on your device, the processes currently running, or the data stored in your device's memory. All such data will be handled in accordance with this policy and relevant law..

1.3 When you top up your account in NS E-PASS, we will collect your top-up order information and usage records. This is necessary to provide and support the top up feature.

1.4 When you use the interoperability features between NS E-PASS and other software or hardware, the providers of such software or hardware may, upon your consent, can obtain the relevant information you provide, disclose, or transfer to NS E-PASS. You are encouraged to carefully review and y understand the features and personal information handling processesof such software or hardware before granting your consent.

1.5 You may enter your personal information such as your gender, region, What's Up, and address in Profile. This information will be uploaded and stored unto our servers, allowing you accessand use when you log in to NS E-PASS on other devices. You may modify or delete such information at any time.

1.6 The third-party services available within NS E-PASS are provided by external providers, and NS E-PASS is unable to acquire the information generated during your use of such third party services. However, a third party may access your location information through NS E-PASS's interfaces upon your explicit consent. Refusing to provide such information may prevent you from using use the above third-party services, but will not affect your use of NS E-PASS features.

1.7 If you contact our customer service personnel, we may request personal information necessary for identity verification to ensure the security of your account. To provide services according to your request, with your authorization, the customer service personnel will verify your relevant information within the scope of your consent. We will use our best efforts to ensure the security and confidentiality of your information through technical and management measures and to use the information only within the authorized scope. Additionally, we may retain your contact information (mobile number or other contact information you use or voluntarily provide), communication records and contents with our customer service, and other necessary information to provide and document customer service.

1.8 According to the requirements of applicable laws and regulations,, we may process your personal information without seeking your consent under the following circumstances:

a) the processing is necessary for the performance of statutory duties or obligations of a personal information processor;

b) the processing is necessary for the conclusion or performance of a contract in which you are a party;

c) the processing is necessary for the response to public health emergencies, or for the protection of life, health and property safety of natural persons in emergencies;

d) the personal information disclosed by you or other legally disclosed information of you is reasonably processed in accordance with the laws;

e) other circumstances as provided by laws or administrative regulations.

1.9 Please note that the features and services we provide are constantly evolving and developed. If the rules for collecting and using yourpersonal information in relation to a certain feature or service are not specified in the provisions above, we will separately inform you of the scope, purpose and method of such information collection. This may be done through page prompts, interaction processes, website announcements and other means to obtain your consent.

1.10 We may use the information collected through certain features or services, for the purpose of enhancing or enabling other NS E-PASS features or services.. For example, information collected during your use of one of the feature may be used to: provide specific content to you or your friends in another feature, displaying advertisement, sending you security alerts for the content you have read, conducting indirect user profiling based on characteristic tags so as to provide more accurate and personalized services and content, and protecting user rights or NS E-PASS ecosystem security.

1.11 To ensure the security of our services, and monitorthe operation status of our applications, we may record relevant information such as your frequency of using our applications, crash data, overall usage information, performance data, and the source of the applications. .This information is used for analytical purposes only and will not be combined with any personally identifiable information you have provided through the application.

1.12 If we intend to use your personal information beyond the purposes you have authorized or beyond what is directly or reasonably related to the original purposes, we will inform and obtain your explicit consent before proceeding with such use.

1.13 At present, the NS E-PASS will not actively obtain your personal information from a third party outside Jamaica North-South Highway Company Ltd. Ifin the future it becomes necessary for us to indirectly obtain your personal information from a third party for business purposes, we will inform you in writing in advane of the source, type, and intended use of your personal information.. If the use of such information collected from a third partyexceeds the scope of previous consentprovided to the third party, we will seek your explicit consent before processing such information.

In addition, we will strictly adhere to the applicable laws and regulations, and will require the third parties to ensurethat the information they provide has been collected and shared lawfully.

2.1 Information storage location

We will store users' personal information collected in accordance with applicable laws and regulations of Jamaica. Ifit becomes necesaary to transfer the storage location of your personal information outside of Jamaica we will strictly comply with the applicable laws and will take appropriate measures to ensure the security and confidentiality of your information.

2.2 Information storage duration

We will retain your personal information for a period that is necessary to fulfill a the purposes outlined in this policy or as required by applicable laws , for example: requirements.

Mobile number: If you need to use NS E-PASS service, we need to retain your mobile number (including the initial registration number and the number that linked to your NS E-PASS account) at all times to ensure your normal use of the service. If you choose to delete your NS E-PASS account, we will delete the associated personal information in accordance with legal

In the event that we discontinue providing our products or services, we will notify you of such change by sending a notification, posting an announcement, or other means, and delete or anonymize your personal information within a reasonable period. ("Anonymization" herein refers to the technical processing of personal information that make it impossible to identify the subject of the personal information and ensure that the processed information cannot be restored. Any anonymized information shall not be considered as personal information.)

2.3 Information deletion

You can access it through https://app.jnshc.com/payweb/html/accountDeletion.html Follow the prompts to delete account information.

We are committed to protecting users' information against theft, improper use, tampering, unauthorized access, or leakage.

We will use various security measures within a reasonable degree of care to protect the security of information. For example, we will use encryption technologies (such as SSL), de-identification, anonymization, and other methods to protect your personal information.

We will enhance the security of the software installed on your device using ever-improving technical means to prevent your personal information from leakage. For example, we will perform partial information encryption on your device locally for secure data transmission; we may obtain information about the applications installed on your device, the processes running on your device, or the data stored in the device's memory to defend against viruses, Trojans, or other malicious programs or websites; we may analyze and utilize the data such as unique device identifiers, login IP addresses, operation logs, and location information to take security measures or issue alerts to prevent against illegal acts such as fraud, account theft, and impersonation, and to conduct security inspection.

We have dedicated management policies, operating procedures, and organizations to ensure information security. For example, we strictly restrict personnel who can access the information, require them to comply with confidentiality obligations, and conduct audits.

In the event of security incidents such as personal information leakages we are committed to taking swift and appropriate action. We will assess whether your Personal Data has been compromised by the breach. If there is a potential impact on your privacy, you will be notified of the breach, explain the potential impacts on your privacy, and outline the steps we are taking to rectify the issue.,

4.1 For the purpose of advertising, and evaluating and optimizing advertising results, we need to share some of your data with third-party partners such as advertisers and their agents. We require them to strictly comply with our measures and requirements for data privacy protection, including but not limited to processing data in accordance with data protection agreements, commitment letters and related data processing policies to ensure that the information does not identify an individual, and to ensure privacy security.

4.2 Without your explicit authorization, we will not share to our partners any information that can be used to identify you personally.

4.3 When you log in to any websites or applications operated by third-party entities via your NS E-PASS account, we will provide your personal information to such third-party entities. The specific scope of external provision shall be subject to what you confirm on the interaction page. In addition, we will not provide your personal information to such third parties without obtaining your express consent in advance.

4.4 To ensure the implementation of some independent features, enabling you to use and enjoy more services and features, we will integrate third-party SDK into the application and carefully evaluate the purpose of using such Software Development Kits (SDK). All third-party SDKs integrated into NS E-PASS are subject to strict data protection assessments. We ensure these providers implement data security measures consistent with the standards under the applicable law.

With the development of our business, there may be transactions such as mergers or spin-offs. In the event of the transfer of personal information, we will inform you of the relevant circumstances and continue to protect your personal information in accordance with laws, regulations and standards no lower than those specified in this Policy, or require the new processor to continue protecting your personal information.

5.1 During your use of the NS- E-Pass , you have the following rights under the Data Protection Act, 2020:

Right of Access – You have the right to request copies of your personal information. Subject to certain exceptions, you are entitled to confirmation as to whether, and to what extent, we process your personal data and, if we do, to request access to that data.

Right to Rectification – If the personal data we hold about you is incomplete or inaccurate, you have the right to request that it be corrected or completed at any time.

Right to Restriction of Processing – You have the right to request the restriction of the processing of your personal information in certain circumstances.

Right to Object to Processing – You have the right to object to the processing of your personal information in certain circumstances.

Right to Data Portability – You have the right to request that we transfer the personal information you provided to another organisation, or to you directly, in certain circumstances.

Right to Consent and Withdrawal of Consent – Where your personal data is processed based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out before your consent was withdrawn.

Right to Restrict Automated Decision-Making – You have the right to request that no decision which significantly affects you is made solely by automated processing of your personal data.

The ability to exercise these rights may depend on various factors, including legal or regulatory obligations. In some cases, we may not be able to fulfill your request where an exemption applies.

5.2 How to exercise your rights

You may exercise any of the rights available to you by contacting us using the information found in at section 9 of this policy. We will examine your request and respond in accordance with the relevant law.

Your request must specify which right(s) you wish to exercise and include your name and contact information (including your telephone number, email address and/or postal address) so that we may contact you to confirm your identity and respond to your request.

This Policy may be revised periodically.. In the event of any major changes to the provisions in this Policy, we will provide you with the updated Policy by appnotifications, pop-up window, or other legally acceptable means.

We place great value on the protection of minors' personal information. As required by applicable laws and regulations, if you are a user under the age of 18, you should obtain the written consent of your parent or statutory guardian prior to the use of NS E-PASS services. If you, as the parent or statutory guardian of a minor, have any questions about the personal information of minors, please contact us through the means as stated in Section 9.

8.1 For certain specific services or features of NS E-PASS, we may separately inform you of the purpose, method or scope of processing of personal information through interactive text, product interfaces, pop-up windows, etc. In the event of any inconsistency between our separate notification and this Policy, the former will prevail.

If you have any questions, complaints or suggestions about this Policy or personal information protection, please contact us through any of the following methods:

1) Phone:
1 876 903-8646/1 888 429-5674;

2) Email:
[email protected]/[email protected] ;

3) Mail:
Management Centre, Treadways District, P.O. 4638, Linstead, St. Catherine, Jamaica.

We will review your feedback , and aim to respond to you within fifteen calendar days,..

Jamaica North-South Highway Company Ltd